Opinion

Eva Carrillo v. County of Los Angeles

Court
District Court, C.D. California
Filed
Mar 18, 2021
Cited by
0 cases
Authority
More cited than 17.9%

distinguishing “good cause” 18 showing for sealing documents produced in discovery from “compelling reasons” 19 standard when merits-related documents are part of court record

How later courts described this case

  • distinguishing “good cause” 18 showing for sealing documents produced in discovery from “compelling reasons” 19 standard when merits-related documents are part of court record
  • even stipulated protective orders 17 require good cause showing

Written by the judges who cited it.

The opinion

1 JILL WILLIAMS – State Bar No. 221793

EMILY SUHR – State Bar No. 306658

2 CARPENTER, ROTHANS & DUMONT

500 S. Grand Avenue, 19th Floor

3 Los Angeles, CA 90071

(213) 228-0400 / (213) 228-0401 (fax)

4 jwilliams@crdlaw.com / esuhr@crdlaw.com

5 Attorneys for Defendants

County of Los Angeles (also erroneously sued herein

6 as the “Los Angeles County Sheriff’s Department”)

and Deputy Christian Campos

7

8

9 UNITED STATES DISTRICT COURT

10 CENTRAL DISTRICT OF CALIFORNIA

11

12 EVA CARRILLO, individually and as ) Case No.: 2:21-CV-00058-SVW-RAO

the personal representative of RAUL )

13 ANTONIO BARRETO, deceased ) STIPULATED PROTECTIVE

) ORDER1

14 Plaintiff, )

)

15 vs. )

)

16 COUNTY OF LOS ANGELES, LOS )

ANGELES COUNTY SHERIFF’S )

17 DEPARTMENT, DEPUTY GOMEZ )

(No. 655591), DEPUTY CAMPOS )

18 (No. 616223), and DOES 1 to 10, )

)

19 Defendants. )

)

20

21

22

1. A. PURPOSES AND LIMITATIONS

23

Discovery in this action is likely to involve production of confidential,

24

proprietary or private information for which special protection from public

25

26

27 1 This Stipulated Protective Order is substantially based on the model protective

order provided under Magistrate Judge Rozella A. Oliver’s Procedures.

1 disclosure and from use for any purpose other than prosecuting this litigation may

2 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to

3 enter the following Stipulated Protective Order. The parties acknowledge that this

4 Order does not confer blanket protections on all disclosures or responses to

5 discovery and that the protection it affords from public disclosure and use extends

6 only to the limited information or items that are entitled to confidential treatment

7 under the applicable legal principles.

8

9 B. GOOD CAUSE STATEMENT

10 This action is likely to involve confidential and sensitive information for

11 which special protection from public disclosure and from use for any purpose other

12 than prosecution of this action is warranted. Such confidential and proprietary

13 materials and information may consist of, among other things, video depicting the

14 interior of a jail facility, private medical and mental health records, investigation

15 materials, police reports, confidential informant/witness information, financial

16 materials, confidential peace officer personnel materials, investigation techniques,

17 information implicating privacy rights of third parties, personal information

18 otherwise generally unavailable to the public, and other private and confidential

19 materials for which special protection from public disclosure and from use for any

20 purpose other than prosecution of this action is warranted.

21 Accordingly, to expedite the flow of information, to facilitate the prompt

22 resolution of disputes over confidentiality of discovery materials, to adequately

23 protect information the parties are entitled to keep confidential, to ensure that the

24 parties are permitted reasonable necessary uses of such material in preparation for

25 and in the conduct of trial, to address their handling at the end of the litigation, and

26 serve the ends of justice, a protective order for such information is justified in this

27 matter. It is the intent of the parties that information will not be designated as

1 confidential for tactical reasons and that nothing be so designated without a good

2 faith belief that it has been maintained in a confidential, non-public manner, and

3 there is good cause why it should not be part of the public record of this case.

4

5 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL

6 The parties further acknowledge, as set forth in Section 12.3, below, that this

7 Stipulated Protective Order does not entitle them to file confidential information

8 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed

9 and the standards that will be applied when a party seeks permission from the court

10 to file material under seal.

11 There is a strong presumption that the public has a right of access to judicial

12 proceedings and records in civil cases. In connection with non-dispositive motions,

13 good cause must be shown to support a filing under seal. See Kamakana v. City and

14 County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006); Phillips v. Gen. Motors

15 Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002); Makar-Welbon v. Sony Electrics,

16 Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders

17 require good cause showing), and a specific showing of good cause or compelling

18 reasons with proper evidentiary support and legal justification, must be made with

19 respect to Protected Material that a party seeks to file under seal. The parties’ mere

20 designation of Disclosure or Discovery Material as CONFIDENTIAL does not—

21 without the submission of competent evidence by declaration, establishing that the

22 material sought to be filed under seal qualifies as confidential, privileged, or

23 otherwise protectable—constitute good cause.

24 Further, if a party requests sealing related to a dispositive motion or trial, then

25 compelling reasons, not only good cause, for the sealing must be shown, and the

26 relief sought shall be narrowly tailored to serve the specific interest to be protected.

27 See Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 2010). For

1 each item or type of information, document, or thing sought to be filed or introduced

2 under seal in connection with a dispositive motion or trial, the party seeking

3 protection must articulate compelling reasons, supported by specific facts and legal

4 justification, for the requested sealing order. Again, competent evidence supporting

5 the application to file documents under seal must be provided by declaration.

6 Any document that is not confidential, privileged, or otherwise protectable in

7 its entirety will not be filed under seal if the confidential portions can be redacted.

8 If documents can be redacted, then a redacted version for public viewing, omitting

9 only the confidential, privileged, or otherwise protectable portions of the document

10 shall be filed. Any application that seeks to file documents under seal in their

11 entirety should include an explanation of why redaction is not feasible.

12

13 2. DEFINITIONS

14 2.1 Action: Eva Carrillo, individually and as the personal representative of

15 Raul Antonio Barreto, deceased v. County of Los Angeles, et al.

16 2.2 Challenging Party: a Party or Non-Party that challenges the

17 designation of information or items under this Order.

18 2.3 “CONFIDENTIAL” Information or Items: information (regardless of

19 how it is generated, stored or maintained) or tangible things that qualify for

20 protection under Federal Rule of Civil Procedure 26(c), and as specified above in

21 the Good Cause Statement.

22 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as

23 their support staff).

24 2.5 Designating Party: a Party or Non-Party that designates information or

25 items that it produces in disclosures or in responses to discovery as

26 “CONFIDENTIAL.”

27 2.6 Disclosure or Discovery Material: all items or information, regardless

1 of the medium or manner in which it is generated, stored, or maintained (including,

2 among other things, testimony, transcripts, and tangible things) that are produced or

3 generated in disclosures or responses to discovery in this matter.

4 2.7 Expert: a person with specialized knowledge or experience in a matter

5 pertinent to the litigation who has been retained by a Party or its counsel to serve as

6 an expert witness or as a consultant in this Action.

7 2.8 House Counsel: attorneys who are employees of a party to this Action.

8 House Counsel does not include Outside Counsel of Record or any other outside

9 counsel.

10 2.9 Non-Party: any natural person, partnership, corporation, association or

11 other legal entity not named as a Party to this action.

12 2.10 Outside Counsel of Record: attorneys who are not employees of a

13 party to this Action but are retained to represent or advise a party to this Action and

14 have appeared in this Action on behalf of that party or are affiliated with a law firm

15 that has appeared on behalf of that party, and includes support staff.

16 2.11 Party: any party to this Action, including all of its officers, directors,

17 employees, consultants, retained experts, and Outside Counsel of Record (and their

18 support staffs).

19 2.12 Producing Party: a Party or Non-Party that produces Disclosure or

20 Discovery Material in this Action.

21 2.13 Professional Vendors: persons or entities that provide litigation

22 support services (e.g., photocopying, videotaping, translating, preparing exhibits or

23 demonstrations, and organizing, storing, or retrieving data in any form or medium)

24 and their employees and subcontractors.

25 2.14 Protected Material: any Disclosure or Discovery Material that is

26 designated as “CONFIDENTIAL.”

27 2.15 Receiving Party: a Party that receives Disclosure or Discovery

1 Material from a Producing Party.

2 3. SCOPE

3 The protections conferred by this Stipulation and Order cover not only

4 Protected Material (as defined above), but also (1) any information copied or

5 extracted from Protected Material; (2) all copies, excerpts, summaries, or

6 compilations of Protected Material; and (3) any testimony, conversations, or

7 presentations by Parties or their Counsel that might reveal Protected Material.

8 Any use of Protected Material at trial shall be governed by the orders of the

9 trial judge. This Order does not govern the use of Protected Material at trial.

10

11 4. DURATION

12 Once a case proceeds to trial, information that was designated as

13 CONFIDENTIAL or maintained pursuant to this protective order used or introduced

14 as an exhibit at trial becomes public and will be presumptively available to all

15 members of the public, including the press, unless compelling reasons supported by

16 specific factual findings to proceed otherwise are made to the trial judge in advance

17 of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause”

18 showing for sealing documents produced in discovery from “compelling reasons”

19 standard when merits-related documents are part of court record). Accordingly, the

20 terms of this protective order do not extend beyond the commencement of the trial.

21

22 5. DESIGNATING PROTECTED MATERIAL

23 5.1 Exercise of Restraint and Care in Designating Material for Protection.

24 Each Party or Non-Party that designates information or items for protection under

25 this Order must take care to limit any such designation to specific material that

26 qualifies under the appropriate standards. The Designating Party must designate for

27 protection only those parts of material, documents, items or oral or written

1 communications that qualify so that other portions of the material, documents, items

2 or communications for which protection is not warranted are not swept unjustifiably

3 within the ambit of this Order.

4 Mass, indiscriminate or routinized designations are prohibited. Designations

5 that are shown to be clearly unjustified or that have been made for an improper

6 purpose (e.g., to unnecessarily encumber the case development process or to impose

7 unnecessary expenses and burdens on other parties) may expose the Designating

8 Party to sanctions.

9 If it comes to a Designating Party’s attention that information or items that it

10 designated for protection do not qualify for protection, that Designating Party must

11 promptly notify all other Parties that it is withdrawing the inapplicable designation.

12 5.2 Manner and Timing of Designations. Except as otherwise provided in

13 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise

14 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection

15 under this Order must be clearly so designated before the material is disclosed or

16 produced.

17 Designation in conformity with this Order requires:

18 (a) for information in documentary form (e.g., paper or electronic

19 documents, but excluding transcripts of depositions or other pretrial or trial

20 proceedings), that the Producing Party affix at a minimum, the legend

21 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that

22 contains protected material. If only a portion of the material on a page qualifies for

23 protection, the Producing Party also must clearly identify the protected portion(s)

24 (e.g., by making appropriate markings in the margins).

25 A Party or Non-Party that makes original documents available for inspection

26 need not designate them for protection until after the inspecting Party has indicated

27 which documents it would like copied and produced. During the inspection and

1 before the designation, all of the material made available for inspection shall be

2 deemed “CONFIDENTIAL.” After the inspecting Party has identified the

3 documents it wants copied and produced, the Producing Party must determine which

4 documents, or portions thereof, qualify for protection under this Order. Then,

5 before producing the specified documents, the Producing Party must affix the

6 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a

7 portion of the material on a page qualifies for protection, the Producing Party also

8 must clearly identify the protected portion(s) (e.g., by making appropriate markings

9 in the margins).

10 (b) for testimony given in depositions that the Designating Party identifies

11 the Disclosure or Discovery Material on the record, before the close of the

12 deposition all protected testimony.

13 (c) for information produced in some form other than documentary and

14 for any other tangible items, that the Producing Party affix in a prominent place on

15 the exterior of the container or containers in which the information is stored the

16 legend “CONFIDENTIAL.” If only a portion or portions of the information

17 warrants protection, the Producing Party, to the extent practicable, shall identify the

18 protected portion(s).

19 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent

20 failure to designate qualified information or items does not, standing alone, waive

21 the Designating Party’s right to secure protection under this Order for such material.

22 Upon timely correction of a designation, the Receiving Party must make reasonable

23 efforts to assure that the material is treated in accordance with the provisions of this

24 Order.

25

26 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS

27 6.1 Timing of Challenges. Any Party or Non-Party may challenge a

1 designation of confidentiality at any time that is consistent with the Court’s

2 Scheduling Order.

3 6.2 Meet and Confer. The Challenging Party shall initiate the dispute

4 resolution process under Local Rule 37.1 et seq.

5 6.3 The burden of persuasion in any such challenge proceeding shall be on

6 the Designating Party. Frivolous challenges, and those made for an improper

7 purpose (e.g., to harass or impose unnecessary expenses and burdens on other

8 parties) may expose the Challenging Party to sanctions. Unless the Designating

9 Party has waived or withdrawn the confidentiality designation, all parties shall

10 continue to afford the material in question the level of protection to which it is

11 entitled under the Producing Party’s designation until the Court rules on the

12 challenge.

13

14 7. ACCESS TO AND USE OF PROTECTED MATERIAL

15 7.1 Basic Principles. A Receiving Party may use Protected Material that is

16 disclosed or produced by another Party or by a Non-Party in connection with this

17 Action only for prosecuting, defending or attempting to settle this Action. Such

18 Protected Material may be disclosed only to the categories of persons and under the

19 conditions described in this Order. When the Action has been terminated, a

20 Receiving Party must comply with the provisions of section 13 below (FINAL

21 DISPOSITION).

22 Protected Material must be stored and maintained by a Receiving Party at a

23 location and in a secure manner that ensures that access is limited to the persons

24 authorized under this Order.

25 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless

26 otherwise ordered by the court or permitted in writing by the Designating Party, a

27 Receiving Party may disclose any information or item designated

1 “CONFIDENTIAL” only to:

2 (a) the Receiving Party’s Outside Counsel of Record in this Action, as

3 well as employees of said Outside Counsel of Record to whom it is reasonably

4 necessary to disclose the information for this Action;

5 (b) the officers, directors, and employees (including House Counsel) of

6 the Receiving Party to whom disclosure is reasonably necessary for this Action;

7 (c) Experts (as defined in this Order) of the Receiving Party to whom

8 disclosure is reasonably necessary for this Action and who have signed the

9 “Acknowledgment and Agreement to Be Bound” (Exhibit A);

10 (d) the court and its personnel;

11 (e) court reporters and their staff;

12 (f) professional jury or trial consultants, mock jurors, and Professional

13 Vendors to whom disclosure is reasonably necessary for this Action and who have

14 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);

15 (g) the author or recipient of a document containing the information or a

16 custodian or other person who otherwise possessed or knew the information;

17 (h) during their depositions, witnesses, and attorneys for witnesses, in the

18 Action to whom disclosure is reasonably necessary provided: (1) the deposing party

19 requests that the witness sign the form attached as Exhibit A hereto; and (2) they

20 will not be permitted to keep any confidential information unless they sign the

21 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise

22 agreed by the Designating Party or ordered by the court. Pages of transcribed

23 deposition testimony or exhibits to depositions that reveal Protected Material may

24 be separately bound by the court reporter and may not be disclosed to anyone except

25 as permitted under this Stipulated Protective Order; and

26 (i) any mediator or settlement officer, and their supporting personnel,

27 mutually agreed upon by any of the parties engaged in settlement discussions.

1

2 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED

3 IN OTHER LITIGATION

4 If a Party is served with a subpoena or a court order issued in other litigation

5 that compels disclosure of any information or items designated in this Action as

6 “CONFIDENTIAL,” that Party must:

7 (a) promptly notify in writing the Designating Party. Such notification

8 shall include a copy of the subpoena or court order;

9 (b) promptly notify in writing the party who caused the subpoena or order

10 to issue in the other litigation that some or all of the material covered by the

11 subpoena or order is subject to this Protective Order. Such notification shall include

12 a copy of this Stipulated Protective Order; and

13 (c) cooperate with respect to all reasonable procedures sought to be

14 pursued by the Designating Party whose Protected Material may be affected.

15 If the Designating Party timely seeks a protective order, the Party served with

16 the subpoena or court order shall not produce any information designated in this

17 action as “CONFIDENTIAL” before a determination by the court from which the

18 subpoena or order issued, unless the Party has obtained the Designating Party’s

19 permission. The Designating Party shall bear the burden and expense of seeking

20 protection in that court of its confidential material and nothing in these provisions

21 should be construed as authorizing or encouraging a Receiving Party in this Action

22 to disobey a lawful directive from another court.

23

24 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE

25 PRODUCED IN THIS LITIGATION

26 (a) The terms of this Order are applicable to information produced by a

27 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information

1 produced by Non-Parties in connection with this litigation is protected by the

2 remedies and relief provided by this Order. Nothing in these provisions should be

3 construed as prohibiting a Non-Party from seeking additional protections.

4 (b) In the event that a Party is required, by a valid discovery request, to

5 produce a Non-Party’s confidential information in its possession, and the Party is

6 subject to an agreement with the Non-Party not to produce the Non-Party’s

7 confidential information, then the Party shall:

8 (1) promptly notify in writing the Requesting Party and the Non-Party

9 that some or all of the information requested is subject to a confidentiality

10 agreement with a Non-Party;

11 (2) promptly provide the Non-Party with a copy of the Stipulated

12 Protective Order in this Action, the relevant discovery request(s), and a reasonably

13 specific description of the information requested; and

14 (3) make the information requested available for inspection by the

15 Non-Party, if requested.

16 (c) If the Non-Party fails to seek a protective order from this court within

17 14 days of receiving the notice and accompanying information, the Receiving Party

18 may produce the Non-Party’s confidential information responsive to the discovery

19 request. If the Non-Party timely seeks a protective order, the Receiving Party shall

20 not produce any information in its possession or control that is subject to the

21 confidentiality agreement with the Non-Party before a determination by the court.

22 Absent a court order to the contrary, the Non-Party shall bear the burden and

23 expense of seeking protection in this court of its Protected Material.

24

25 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

26 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed

27 Protected Material to any person or in any circumstance not authorized under this

1 Stipulated Protective Order, the Receiving Party must immediately (a) notify in

2 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts

3 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or

4 persons to whom unauthorized disclosures were made of all the terms of this Order,

5 and (d) request such person or persons to execute the “Acknowledgment and

6 Agreement to Be Bound” that is attached hereto as Exhibit A.

7

8 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

9 PROTECTED MATERIAL

10 When a Producing Party gives notice to Receiving Parties that certain

11 inadvertently produced material is subject to a claim of privilege or other protection,

12 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil

13 Procedure 26(b)(5)(B). This provision is not intended to modify whatever

14 procedure may be established in an e-discovery order that provides for production

15 without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and

16 (e), insofar as the parties reach an agreement on the effect of disclosure of a

17 communication or information covered by the attorney-client privilege or work

18 product protection, the parties may incorporate their agreement in the stipulated

19 protective order submitted to the court.

20

21 12. MISCELLANEOUS

22 12.1 Right to Further Relief. Nothing in this Order abridges the right of any

23 person to seek its modification by the Court in the future.

24 12.2 Right to Assert Other Objections. By stipulating to the entry of this

25 Protective Order, no Party waives any right it otherwise would have to object to

26 disclosing or producing any information or item on any ground not addressed in this

27

1 Stipulated Protective Order. Similarly, no Party waives any right to object on any

2 ground to use in evidence of any of the material covered by this Protective Order.

3 12.3 Filing Protected Material. A Party that seeks to file under seal any

4 Protected Material must comply with Local Civil Rule 79-5. Protected Material

5 may only be filed under seal pursuant to a court order authorizing the sealing of the

6 specific Protected Material at issue. If a Party’s request to file Protected Material

7 under seal is denied by the court, then the Receiving Party may file the information

8 in the public record unless otherwise instructed by the court.

9

10 13. FINAL DISPOSITION

11 After the final disposition of this Action, as defined in paragraph 4, within 60

12 days of a written request by the Designating Party, each Receiving Party must return

13 all Protected Material to the Producing Party or destroy such material. As used in

14 this subdivision, “all Protected Material” includes all copies, abstracts, compilations,

15 summaries, and any other format reproducing or capturing any of the Protected

16 Material. Whether the Protected Material is returned or destroyed, the Receiving

17 Party must submit a written certification to the Producing Party (and, if not the same

18 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies

19 (by category, where appropriate) all the Protected Material that was returned or

20 destroyed and (2) affirms that the Receiving Party has not retained any copies,

21 abstracts, compilations, summaries or any other format reproducing or capturing any

22 of the Protected Material. Notwithstanding this provision, Counsel are entitled to

23 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing

24 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert

25 reports, attorney work product, and consultant and expert work product, even if such

26 materials contain Protected Material. Any such archival copies that contain or

27 constitute Protected Material remain subject to this Protective Order as set forth in

1 || Section 4 (DURATION).

2

3 || 14. VIOLATION

4 || Any violation of this Order may be punished by appropriate measures including,

5 || without limitation, contempt proceedings and/or monetary sanctions.

6

7 || ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD.

8

9 || DATED: March 18, 2021 LAW OFFICE OF JOHN BURTON

10

11 By: /s/ John Burton

John Burton

Attorneys for Plaintiff

13

14

DATED: March 18, 2021 CARPENTER, ROTHANS & DUMONT LLP

15

16 .

By: /s/ Emily Suhr?

17 Emily Suhr

18 Attorney for Defendants,

County of Los Angeles and

19 Deputy Christian Campos

20

FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

DATED: March 18, 2021

23 | Repells a, OC

24 || HON. ROZELLA A. OLIVER

95 United States Magistrate Judge

26

27 || * As the filer of this Stipulated Protective Order, I attest that John Burton concurs in

the content of the Stipulation and has authorized its filing.

28

OTINT TT ATTMEA NN CATO SCUTIt?7™m CAM TrAVrN

1 EXHIBIT A

2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

3

4 I, _____________________________ [print or type full name], of

5 _________________ [print or type full address], declare under penalty of perjury

6 that I have read in its entirety and understand the Stipulated Protective Order that

7 was issued by the United States District Court for the Central District of California

8 on [date] in the case of Eva Carrillo, individually and as the personal representative

9 of Raul Antonio Barreto, deceased v. County of Los Angeles, et al., Case No.: 2:21-

10 CV-00058-SVW-RAO, I agree to comply with and to be bound by all the terms of

11 this Stipulated Protective Order and I understand and acknowledge that failure to so

12 comply could expose me to sanctions and punishment in the nature of contempt. I

13 solemnly promise that I will not disclose in any manner any information or item that

14 is subject to this Stipulated Protective Order to any person or entity except in strict

15 compliance with the provisions of this Order.

16 I further agree to submit to the jurisdiction of the United States District Court

17 for the Central District of California for enforcing the terms of this Stipulated

18 Protective Order, even if such enforcement proceedings occur after termination of

19 this action. I hereby appoint __________________________ [print or type full

20 name] of _______________________________________ [print or type full address

21 and telephone number] as my California agent for service of process in connection

22 with this action or any proceedings related to enforcement of this Stipulated

23 Protective Order.

24 Date: ______________________________________

25 City and State where sworn and signed: _________________________________

26 Printed name: _______________________________

27 Signature: __________________________________

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.

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